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The Department of Information Technology & Telecommunications has provided testimony and submitted comments and filings to a number of local, state, and federal entities. PDF versions of these documents can be found in the following categories:
Telecommunications legislation and City regulations affecting the operations of the Franchise/Legal division can be found on each of the relevant franchise pages.
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National Telecommunications and Information Administration (NTIA) | ||
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ARRA Comments In April 2009, DoITT submitted comments to the NTIA regarding the American Recovery and Reinvestment Act of 2009 Broadband Initiatives. The comments discuss the results from the City’s Broadband Needs Assessment Study, which found that, while City residents have ubiquitous access to broadband service, with virtually every household currently being “passed” by one or more broadband provider, broadband adoption among low-income and other vulnerable populations is low. The comments describe the reasons for low subscribership among these communities – e.g., affordability, computer literacy, and value perception - and emphasize that increasingly these demand-side problems will be the major impediments to greater broadband usage nationwide. Thus, the comments urge NTIA in allocating funding pursuant to the Congressionally mandated Broadband Technology Opportunities Program to allot at least half of the available funding to programs that seek to address demand-side problems.  NTIA ARRA Comments, April 2009 | |
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Federal Communications Commission (FCC) | ||
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ARRA Comments In April 2009, DoITT submitted comments to the FCC regarding the American Recovery and Reinvestment Act of 2009 Broadband Initiatives. The City urged the Federal Communications Commission, in its consultative role regarding the broadband provisions of the ARRA, to define “underserved areas” as those municipalities, or other political subdivisions, or geographic locations, with a significant number of low-income residents, or members of other vulnerable communities (e.g., disabled or older adults), in light of the significantly lower than average adoption rates among such residents. The City stated that such status as an “underserved area” should apply irrespective of whether the relevant area includes physical infrastructure that can theoretically supply broadband services to the population. FCC ARRA Comments, April 2009 | |
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700 MHz Proceeding In May 2007, DoITT submitted comments in response to a FCC further notice of proposed rulemaking regarding a proposal that would modify existing allocations of the 700 MHz spectrum for public safety and use this spectrum in conjunction with commercial spectrum for a joint commercial/public safety nationwide broadband interoperable network. The filing described the City’s plans to deploy a broadband network for public safety and certain concerns associated with the FCC’s proposal. 700 MHz Comments, May 2007 (PDF) | |
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6.25 KHz Proceeding In May 2007, DoITT, jointly with the New York City Police and Fire Departments, filed a petition for reconsideration describing the problems associated with the FCC’s recent determination to move rapidly towards the use of 6.25 KHz technology in the 150-174 MHz and 421-512 MHz bands. The petition outlined the problems of stranded investment, the effect the FCC’s order would have on ongoing interoperability efforts, as well as the general complexities associated with migrating to narrower bandwidth. In July 2007, DoITT, jointly with the New York City Police and Fire Departments, filed reply comments noting again the City’s concerns about a rapid transition to the use of 6.25 KHz technology and outlining the supporting statements made by all the other commenters in the proceeding. Petition for Reconsideration Narrowbanding, May 2007 (PDF)Reply Comments Narrowbanding, July 2007 (PDF) | |
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White Spaces Proceeding In March 2007, DoITT filed reply comments in response to a FCC further notice of proposed rulemaking regarding transmissions by new low power devices on channels in between broadcast television frequencies (i.e., “white spaces”). In its reply comments, DoITT urged the FCC to ensure that its proceeding adequately addressed the need for testing and technical safeguards to avert the potentially destructive impact that the introduction of new devices in white spaces could have on existing wireless microphone use. White Spaces Reply Comments, March 2007 (PDF) | |
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Verizon Forebearance Proceeding In March 2007, DoITT submitted comments in response to a FCC public notice regarding a petition of Verizon Telephone Companies seeking forbearance from certain unbundling requirements pursuant to the federal Communications Act and FCC dominant carrier regulations in the New York metropolitan statistical area (MSA) . The comments stated that, while the City supports any initiatives to further competition in the New York MSA, the FCC should consider carefully the unique position that Verizon has in the marketplace as the incumbent local exchange carrier. Verizon Forebearance Petition, March 2007 (PDF) | |
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Proceeding on Competition for the Delivery of Video Programming In November 2006, DoITT filed comments in response to a Federal Communications Commission notice asking about, among other things, the impact of local and state franchising requirements on competition in the video marketplace. The comments described the City’s competitively neutral cable franchising process and how this process has enabled the City to address local concerns about the terms and conditions under which cable service is provided, in a manner consistent with the Cable Act. The comments also described how the City’s cable franchising process has helped to further the FCC’s goal of ensuring that local residents have the means to receive diverse programming. Video Programming Comments, November 2006 (PDF) | |
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US Congress | ||
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700 MHz On June 14, 2007, DoITT Commissioner, Paul Cosgrave, testified before the U.S. Senate Committee on Commerce, Science and Transportation regarding a proposal by Frontline Wireless for the development of a nationwide broadband network for public safety using a portion of the 700 MHz spectrum that had been previously allocated to public safety for wideband use. In his testimony, the DoITT Commissioner outlined the City’s concerns with this proposal. Nationwide Broadband Network Comments, June 2007 (PDF) | |
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Public Service Commission, New York State (PSC) | ||
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PSC Proceeding Concerning Wireless Facility Attachments to Utility Distribution Poles In September 2007, DoITT filed comments in the New York State Public Service Commission’s proceeding on wireless facility attachments to utility distribution poles. The comments urged the Commission, in its proceeding, to ensure that it not take any action that would restrict the rights of, or impose obligations on, property owners or managers who are not themselves utilities but who hold title to or management responsibility for underlying property on which utility distribution poles may be located. PSC Wireless Facility Attachment Proceeding, September 2007 (PDF) | |
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Intermodal Competition In 2005, DoITT filed reply comments in a New York State Public Service Commission proceeding regarding intermodal competition. The reply comments discuss: 1) equal treatment for competing providers; 2) the importance of maintaining a wireline infrastructure; 3) service quality; 4) service pricing plans; 5) information the Commission might consider gathering about broadband deployment; and 6) the importance of retaining the Commission’s complaint processes. Comments Intermodal Competition, 2005 (PDF) | |
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City Council Testimony | ||
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Authorizing Resoluton New Cable Franchises, August 2006 In August 2006, DoITT testified before the City Council Subcommittee on Zoning and Franchises regarding a proposed authorizing resolution to permit DoITT to negotiate with cable operators for new cable franchises, as well as the renewal of existing franchises. The testimony described the cable franchising process in the City and the need for a new authorizing resolution. City Council Testimony: Authorizing Resolution New Cable Franchises, August 2006 (PDF) | |
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 Documents on this page may be Adobe Acrobat files. Download the free Adobe Acrobat Reader.
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